David H. Kennedy v. Susan Q. Kennedy

Child support: modification: limits to retroactivity

CSA No. 0029, Sept. Term 2011. Opinion by Salmon, J., retired, specially assigned. Unreported. Filed May 10, 2012. Appeal from Prince George’s County. RecordFax #12-0510-11 pages.

Even though the circumstances likely would have warranted a modification of child support more than a year earlier, the court’s authority to make support retroactive was limited by the date appellant filed his motion for modification; nor did the court have the authority to go back further based on an earlier motion by appellant’s ex-wife, which she had withdrawn before the court ruled on appellant’s motion.

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